イギリスの暗号資産課税

HMRC Cryptoassets Manual CRYPTO22050 — a chargeable asset, which is what brings a disposal inside TCGA 1992 at all

「Tokens are digital and therefore intangible, but count as a 'chargeable asset' for Capital Gains Tax if they're both: capable of being owned, have a value that can be realised」

2026/11/06に出典で確認

HMRC Cryptoassets Manual CRYPTO10100 — what HMRC calls a cryptoasset

「Cryptoassets (also referred to as 'tokens' or 'cryptocurrency') are digital representation of value that relies on a cryptographically secured distributed ledger or similar technology to validate and secure transactions」

2026/11/06に出典で確認

CRYPTO23000 — no source is prescribed: the Bank of England's daily rate is ours, applied consistently, and the document states the methodology as the page asks

「Reasonable care should be taken to arrive at an appropriate valuation for the transaction using a consistent methodology. Details of the valuation methodology should be kept.」

2026/11/01に出典で確認

TCGA 1992 s.105(1)

「all the securities so acquired shall be treated as acquired by a single transaction and all the securities so disposed of shall be treated as disposed of by a single transaction, and … all the securities so acquired shall, so far as their quantity does not exceed that of the securities so disposed of, be identified with those securities」

2026/11/01に出典で確認

TCGA 1992 s.106A(5)

「if within the period of thirty days after the disposal the person making it acquires securities of the same class, the securities disposed of shall be identified— (a) with securities acquired by him within that period, rather than with other securities」

2026/11/01に出典で確認

TCGA 1992 s.105(2), s.105(3)

「the disposal shall be treated as diminishing a quantity of securities subsequently acquired, and as so diminishing any quantity so acquired at an earlier date, rather than one so acquired at a later date」

2026/11/01に出典で確認

CRYPTO22200 — pooling reaches crypto through the second limb of s.104(3), and an NFT reaches none of the rules

「Non-Fungible Tokens (NFTs) are separately identifiable and so are not pooled and no matching rules are applied.」

2026/11/01に出典で確認

TCGA 1992 s.104(1), s.104(3) — one holding per token for the person, with no notion of a wallet or an account

「Any number of securities of the same class acquired by the same person in the same capacity shall for the purposes of this Act (subject to express provision to the contrary) be regarded as indistinguishable parts of a single asset」

2026/11/01に出典で確認

CRYPTO22200 — every unit of a token is in that token's pool, and each pool has one cost

「Each type of token will need its own pool … its own 'pooled allowable cost' associated with it.」

2026/11/01に出典で確認

TCGA 1992 s.1H(3) — the Act knows no holding period for a cryptoasset: every chargeable gain of the year is charged, however long the units were held

「Chargeable gains accruing in a tax year to an individual are charged to capital gains tax at a rate of 18% or 24%」

2026/11/01に出典で確認

CRYPTO61620, CRYPTO61650

「the market value in sterling of the tokens received」

2026/11/01に出典で確認

CRYPTO22100

「selling tokens for money … exchanging tokens for a different type of token … using tokens to pay for goods or services … giving away tokens」

2026/11/01に出典で確認

CRYPTO61620 — a deposit into a DeFi arrangement is a disposal where beneficial ownership passes, which is the default taken for staking, lending, a liquidity pool and a vault

「Where the recipient of the tokens has the ability to deal with the tokens received as they want then this will be a strong indicator that the recipient has acquired the beneficial ownership」

2026/11/01に出典で確認

CRYPTO61640 — collateral and margin are taken as retained, the arrangement's own terms being what would decide it

「if the DeFi lending platform is specifically restricted from dealing with the tokens received as collateral, this will be a strong indicator that the DeFi lending platform has not acquired beneficial ownership of those tokens. Therefore the borrower has retained beneficial ownership of the tokens and has not made a disposal.」

2026/11/01に出典で確認

CRYPTO22110 — a one-way transfer between ledgers: the cost rolls forward under TCGA 1992 s.43

「HMRC's view is that TCGA92/S43 applies to this type of transaction. The allowable costs in respect of the first cryptoasset are attributed in full to the second cryptoasset.」

2026/11/01に出典で確認

CRYPTO22550 — there is no currency relief and no e-money carve-out: a stablecoin given for the money it is denominated in is an ordinary disposal

「HMRC does not consider cryptoassets to be currency or money … sections 252 and 269 Taxation of Chargeable Gains Act 1992 do not apply」

2026/11/01に出典で確認

ITTOIA 2005 s.783AH with s.783AJ(2), s.783AJ(3)

「The amount of miscellaneous income chargeable to income tax for the tax year is— (a) the miscellaneous income for the tax year, less (b) the deductible amount. … Subject to section 783AK, the deductible amount is equal to the individual's trading allowance for the tax year.」

2026/11/04に出典で確認

ITTOIA 2005 s.783AM(1), s.783AM(2); ITA 2007 s.989

「An individual may elect for partial relief to be given for a tax year … An election must be made on or before the first anniversary of the normal self-assessment filing date for that tax year.」

2026/11/04に出典で確認

CRYPTO21200, CRYPTO21150 — staking and mining rewards where the activity is not a trade

「the pound sterling value (at the time of receipt) of any tokens awarded will be taxable as income (miscellaneous income)」

2026/11/01に出典で確認

CRYPTO21250 — an airdrop, the one fact this law asks the taxpayer

「Income Tax may not apply if they're received: without doing anything in return (for example, not related to any service or other conditions) … Airdrops that are provided in return for, or in expectation of, a service are subject to Income Tax」

2026/11/01に出典で確認

TCGA 1992 s.17(2) with CG14550 and CRYPTO22350 — an airdrop nothing was done for costs nothing, and nothing rolls into it

「Subsection (1) shall not apply to the acquisition of an asset if— (a) there is no corresponding disposal of it, and (b) there is no consideration in money or money's worth or the consideration is of an amount or value lower than the market value of the asset」

2026/11/01に出典で確認

ITTOIA 2005 s.783A(1), s.783AB(1), s.783AC, s.783AD(1) — the trading allowance relieves trading and miscellaneous income together

「For the purposes of this Chapter, an individual's trading allowance for a tax year is £1,000.」

2026/11/01に出典で確認

CRYPTO22300 with TCGA 1992 s.52(4) — the pool's cost is split, and HMRC prescribes no method, so the ratio of the two coins' market values at the split is ours

「Any allowable costs in the section 104 pool of the original cryptoassets are split between the two section 104 pools for the original tokens and the new tokens … Costs must be split on a just and reasonable basis under section 52(4) TCGA 1992. HMRC does not prescribe any particular apportionment method.」

2026/11/01に出典で確認

TCGA 1992 s.17(1)(a) — a gift received has a corresponding disposal, so it is acquired at market value

「a person's acquisition or disposal of an asset shall for the purposes of this Act be deemed to be for a consideration equal to the market value of the asset— (a) where he acquires or, as the case may be, disposes of the asset otherwise than by way of a bargain made at arm's length, and in particular where he acquires or disposes of it by way of gift」

2026/11/01に出典で確認

TCGA 1992 s.58(1A) with s.58(1B) — a gift from a spouse or civil partner passes the giver's own allowable cost instead of a market value, which is why this law asks who gave before it reads a gift

「A and B are to be treated as if B acquired the asset from A for a consideration of such amount as would secure that on the disposal neither a gain nor a loss would accrue to A」

2026/11/01に出典で確認

TCGA 1992 s.17(1)(a) with CRYPTO22100 — giving crypto away is a disposal of it at its market value, so a gain on it is taxed as a sale would be

「a person's acquisition or disposal of an asset shall for the purposes of this Act be deemed to be for a consideration equal to the market value of the asset— (a) where he acquires or, as the case may be, disposes of the asset otherwise than by way of a bargain made at arm's length, and in particular where he acquires or disposes of it by way of gift」

2026/11/01に出典で確認

TCGA 1992 s.58(1A) with s.58(1B) — a gift to a spouse or civil partner living together is no gain and no loss, which is why this law asks who received it

「A and B are to be treated as if B acquired the asset from A for a consideration of such amount as would secure that on the disposal neither a gain nor a loss would accrue to A」

2026/11/01に出典で確認

CRYPTO21100 with s.702 ITEPA 2003 — crypto paid by an employer is a readily convertible asset the employer accounts for

「Where cryptoassets are provided in the form of a readily convertible asset the employer is therefore required to account to HMRC for the tax and National Insurance contributions due on the best estimate of the value of that asset.」

2026/11/01に出典で確認

TCGA 1992 s.17(1)(b) with gov.uk, "Check if you need to pay tax when you receive cryptoassets"

「If you sell the cryptoasset that you've paid Income Tax on at a later date, you should calculate Capital Gains Tax as normal on any increase in the value of the tokens since you received them.」

2026/11/01に出典で確認

TCGA 1992 s.38(1)(a) with CRYPTO22150

「the amount or value of the consideration, in money or money's worth, given by him or on his behalf wholly and exclusively for the acquisition of the asset, together with the incidental costs to him of the acquisition」

2026/11/01に出典で確認

TCGA 1992 s.38(1)(c) with CRYPTO22150, which lists a transaction fee among the allowable costs and apportions the fee of a crypto-for-crypto exchange equally between the disposal and the acquisition

「You can accept that apportioning this type of fee equally between the assets disposed of and the assets acquired (that is a 50/50 split) is just and reasonable in these circumstances」

2026/11/11に出典で確認

CRYPTO22280 with TCGA 1992 s.17(1)(b) — the tokens that pay a fee are themselves disposed of, at market value, and the fee is also an allowable cost of its own transaction

「Fees satisfied in tokens … the fee is given as consideration for a service … market value is to be used」

2026/11/01に出典で確認

ITA 2007 s.152 with s.153; HMRC CRYPTO21300

「But a deduction for that purpose is to be made only from the person's relevant miscellaneous income」

2026/11/02に出典で確認

ITA 2007 s.152(1)

「If in a tax year (“the loss-making year”) a person makes a loss in a relevant transaction, the person may make a claim for loss relief against relevant miscellaneous income」

2026/11/02に出典で確認

ITA 2007 s.155(1)

「So far as a claim for loss relief against relevant miscellaneous income concerns the amount of the loss for a tax year, it must be made not more than 4 years after the end of the tax year」

2026/11/02に出典で確認

CRYPTO10150 with CFM50070 — miscellaneous income is HMRC's own default for an individual's crypto derivative

「Where a derivative is not within Part 7, and is not held for the purposes of a trade or property business, two possibilities for taxation remain - profits may constitute miscellaneous income (formerly Case VI Schedule D), or they may be taxable as capital gains. Normally, taxation as miscellaneous income would take priority over any capital gains charge.」

2026/11/01に出典で確認

TCGA 1992 s.143(1) with s.143(2)(a), s.143(3), s.143(6) and s.143(8) — a future dealt in on a recognised futures exchange, or made with an authorised person, is read as a disposal and not as income, which is why this law asks where the contract was made

「his outstanding obligations under any futures contract entered into in the course of that dealing … shall be regarded as assets to the disposal of which this Act applies」

2026/11/02に出典で確認

ITTOIA 2005 s.779(1) with s.779(2) — the same gain is out of income tax, which is what leaves the disposal of s.143 to tax it

「No liability to income tax arises as a result of Chapter 8 of Part 5 (income not otherwise charged) in respect of a gain arising to a person in the course of dealing in— (a) commodity or financial futures」

2026/11/02に出典で確認

TCGA 1992 s.21(1) with CRYPTO22050 and CRYPTO10450 — a prediction market's share read as a chargeable asset; HMRC has published nothing on such markets

「All forms of property shall be assets for the purposes of this Act, whether situated in the United Kingdom or not, including— (a) options, debts and incorporeal property generally」

2026/11/01に出典で確認

TCGA 1992 s.51(1) with BIM22015 — the reading under which such results are outside capital gains tax altogether

「It is hereby declared that winnings from betting, including pool betting, or lotteries or games with prizes are not chargeable gains, and no chargeable gain or allowable loss shall accrue on the disposal of rights to winnings obtained by participating in any pool betting or lottery or game with prizes.」

2026/11/01に出典で確認

TCGA 1992 s.24(1) — a share its market's resolution left worthless is extinguished then; where HMRC read it as merely worthless, a negligible value claim

「the occasion of the entire loss, destruction, dissipation or extinction of an asset shall, for the purposes of this Act, constitute a disposal of the asset whether or not any capital sum by way of compensation or otherwise is received」

2026/11/01に出典で確認

TCGA 1992 s.1H(3) with s.1I(1)

「If any of an individual's income for a tax year is chargeable to income tax at a higher income tax rate, gains accruing to the individual in the tax year are charged at the rate of 24%」

2026/11/01に出典で確認

TCGA 1992 s.4(2) as substituted by Finance Act 2016 s.83(3), with s.4(2A): 10% and 20% for a gain that is not an upper rate gain, which a cryptoasset is not

「(a) in respect of upper rate gains accruing to a person in a tax year, is 18%, and (b) in respect of gains accruing to a person in a tax year which are not upper rate gains, is 10%」

2026/11/01に出典で確認

TCGA 1992 s.4(2), s.4(4) as substituted by F(No.2)A 2010 Sch. 1 para. 2, in force for gains accruing on or after 23 June 2010 by its para. 12

「the rate of capital gains tax in respect of gains accruing to a person in a tax year is 18% … If income tax is chargeable at the higher rate or the dividend upper rate in respect of any part of the income of an individual for a tax year, the rate of capital gains tax in respect of gains accruing to the individual in the year is 28%」

2026/11/01に出典で確認

TCGA 1992 s.4 as substituted by Finance Act 2008 s.8(1), one rate for everybody — the same Act ended taper relief and the indexation allowance in its Schedule 2, which is why this law is stated from 6 April 2008 and no earlier

「The rate of capital gains tax is 18%.」

2026/11/01に出典で確認

TCGA 1992 s.1(3) — the year's gains less the year's losses, then the losses of earlier years not previously deducted

「Capital gains tax is charged on the total amount of chargeable gains accruing to a person in a tax year after deducting— (a) any allowable losses accruing to the person in the tax year, and (b) so far as not previously deducted under this subsection, any allowable losses accruing to the person in any previous tax year.」

2026/11/01に出典で確認

TCGA 1992 s.1K(1), s.1K(2), s.1K(4) — the annual exempt amount, deducted after the year's own losses and before those of earlier years

「If an individual is (or, apart from this section, would be) chargeable to capital gains tax for a tax year on chargeable gains, the annual exempt amount for the year is to be deducted from those gains (but no further than necessary to eliminate them).」

2026/11/01に出典で確認

TCGA 1992 s.3(1), s.3(2), s.3(5A), s.3(5B) as they stood before Finance Act 2019 rewrote Part 1 — the same exemption and the same order: a year inside it deducts no loss brought forward, a year above it only as far as the excess

「An individual shall not be chargeable to capital gains tax in respect of so much of his taxable amount for any year of assessment as does not exceed the exempt amount for the year … Where … the amount of the adjusted net gains for any year of assessment is equal to or less than the exempt amount for that year, no deduction shall be made for that year in respect of — (a) any allowable losses carried forward from a previous year」

2026/11/01に出典で確認

TCGA 1992 s.16(2A) — a loss is allowable only once it is notified, and the return is that notice

「A loss accruing to a person in a year of assessment shall not be an allowable loss for the purposes of this Act unless, in relation to that year, he gives a notice to an officer of the Board quantifying the amount of that loss」

2026/11/01に出典で確認